Telecom Commission Letter Addressed to John Lawford (PIAC)

Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116

BY EMAIL

John Lawford
Executive Director & Counsel to the Public Interest Advocacy Centre (PIAC)
Counsel to the National Pensioners Federation (NPF), the Council of Senior Citizens’ Organizations of B.C. (COSCO)
lawford@piac.ca
alau@piac.ca

Re:  Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116 – Requests for information

Dear Mr. Lawford:

Pursuant to the procedure set out in Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116, 29 March 2016, attached are requests for information addressed to the Counsel to the National Pensioners Federation (NPF), the Council of Senior Citizens’ Organizations of B.C. (COSCO) and PIAC.
Responses to these requests for information are to be filed with the Commission by 23 August 2016.

Sincerely,

Original signed by Kim Wardle for/

Sheehan Carter
A/Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.    Renée Doiron, CRTC, 819-997-2755, Renee.Doiron@crtc.gc.ca
James Ndirangu, CRTC, 819-997-3670, James.Ndirangu@crtc.gc.ca

Attach. (1)

Attachment 1

  1. Refer to paragraphs 58 to 61 of your intervention, in which you indicated that the privacy rules that would apply to the personal information collected, used, or disclosed over the NG9-1-1 network(s) in Canada are unclear and consist of a patchwork of federal and provincial privacy legislation.
    1. In addition to Ontario, are you aware of any other province/territory that has legislation in place governing the collection, use, and disclosure of personal information related to 9-1-1 communications by PSAPs and/or other emergency responders? If so, provide a description of the legislations and outline the major differences between these different legislations.
    2. Provide your view on the risks and challenges related to privacy issues associated with these different regimes, and the possible gap(s) that exist(s) between provinces and/or territories in this regard.
    3. Provide your view on possible solutions and/or measures that the Commission could implement to mitigate these privacy issues, if any measures are required, taking into account the Commission’s jurisdiction and existing privacy legislation.
  2. Refer to paragraphs 76 to 78 of your intervention, in which you provided a list of proposed reporting and monitoring requirements. For each proposed requirement, explain, with supporting rationale, how the establishment of such a requirement would help with the transition to NG9-1-1 networks or services and afterwards.
  3. Refer to paragraph 46 of your intervention, in which you proposed one national 9-1-1 fund, overseen by a national administrator that would be financed through contributions from Canadian telecommunications service providers (TSPs). You submitted that the Commission may set thresholds for contribution, similar to those for the National Contribution Fund (NCF), and that like the NCF, the national administrator would (i) determine how the funds would be allocated, and (ii) regularly report on these contributions and allocations.
    1. If a new centralized fund, similar to the National Contribution Fund, were created to fund NG9-1-1,
      1. what steps would be required to set up such a fund?
      2. what would be an appropriate contribution formula?
      3. to whom would the obligation to contribute apply?
      4. the national administrator would be responsible for the allocation of funds for the purposes of maintaining and upgrading NG9-1-1 network components. What should be the criteria for allocation and what mechanisms should be used to ensure that the funds are spent for the purpose for which they were allocated?
      5. what should be the associated reporting requirements?
      6. regarding the possibility of existing 9-1-1 networks and NG9-1-1 networks operating concurrently, describe how the existing tariff-based funding model should be transitioned to a centralized funding model?
    2. Describe if and how your proposal of using a centralized fund, overseen by a national administrator, for NG9-1-1 would affect the TSPs’ overall costs of providing NG9-1-1 services; the ease of administration; the transition to NG9-1-1; and consumers.
  4. Refer to paragraph 23, 30, and 31 of your intervention, in which you proposed that there should be one national NG9-1-1 network to serve the whole country, managed by one centralized administrator.
    1. Describe the process and arrangements contemplated with respect to the establishment of the single NG9-1-1 network administrator, including:
      1. Which entity should establish the single NG9-1-1 network administrator?
      2. What would be the NG9-1-1 network administrator’s governance structure and responsibilities?
      3. Would participation in the governance of the single NG9-1-1 network administrator be mandatory or voluntary?
      4. If mandatory, what mechanism would be used to mandate participation?
      5. If voluntary, what mechanisms would be relied upon to ensure that participation is representative and not unduly restricted?
      6. What oversight would the Commission have over the single NG9-1-1 network administrator and how would this oversight be exercised to ensure accountability?
    2. What roles and responsibilities would the network administrator have and how would these be established?
    3. What process would the NG9-1-1 network administrator use to choose an NG9-1-1 network operator to build and maintain the proposed national NG9-1-1 network?
    4. What principles would guide the choice of operator and what, if any, oversight would the Commission have with respect to the selection of the NG9-1-1 network operator and the principles used to guide the selection process?
    5. What formal mechanism, if any, would be instituted for the Commission to oversee this competitive bidding process? 
    6. If an NG9-1-1 network operator is used, how long would the term of the contract to provide the NG9-1-1 network last, and would the process for choosing the national ESInet operator be repeated after the end of every contract term?
    7. Would the national NG9-1-1 network administrator or operator have to establish and enter into 9-1-1 agreements with all provincial and municipal governments responsible for the PSAPs?
    8. Explain why the proposed nationally administered NG9-1-1 network model is more efficient and transparent than the existing model.
    9. Would the single NG9-1-1 network administrator and the NG9-1-1 network operator be considered telecommunications common carriers under the Telecommunications Act?
  5. In paragraph 27 of your intervention, you referred to the Australian model to access emergency services, in which a single national PSAP is managed by the Australian government and operated by Telstra, the equivalent of an ILEC, which transfers calls to the appropriate secondary public safety answering points (PSAP) or emergency dispatchers.
    1. Are you proposing that there should be one national primary PSAP to receive all 9-1-1 calls from subscribers across Canada? Explain what role existing primary PSAPs would play under this proposal or if they would continue to exist. Explain the role and purpose of the NG9-1-1 network under this proposal.
    2. If this model is used for Canada, which entity should be responsible for establishing this national primary PSAP, funding its operations, and determining its 9-1-1 call-handling policies and procedures, as well as arrangements with secondary PSAPs? Explain what roles provincial and municipal governments, whose jurisdiction covers PSAPs, would play in establishing and managing this national primary PSAP. How would arrangements and agreements with secondary PSAPs or emergency dispatchers be established, and under what legislative framework?
  6. Leveraging lessons learned during the recent rollout of Text with 9-1-1 for Canadians who are Deaf, hard of hearing, or have a communication disability, should the rollout of NG9-1-1 services be coordinated and rolled out at the regional, provincial, or individual PSAP level? Explain the benefits, challenges, and risk mitigation strategies associated with your proposal.
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